In a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure, MACPAC commented on a proposed CMS rule on establishing mandatory federal minimum staffing standards and Medicaid payment reporting requirements for nursing facilities. The proposed rule includes several provisions based on the Commission’s prior work to promote transparency and adequate staffing in long-term care.
The Commission emphasized the importance of considering all types of Medicaid payments nursing facilities receive when assessing Medicaid payments. These include base payments for services in both fee for service and managed care, supplemental payments, managed care directed payments, value-based payments, and contributions from residents toward their care expenses. While the proposed rule includes many of these payment types, it does not clearly specify how resident contributions to the costs of their care will be accounted for.
To address this issue, the Commission recommends that CMS collect and report data on all costs related to the care of Medicaid-covered residents, not limited to staffing costs. To ensure consistency in cost measurement, CMS should provide states with additional technical guidance on measuring expenses associated with both direct care workers and support staff.
The Commission also provided technical comments on other aspects of the proposed rule based on MACPAC’s prior analyses of nursing facilities, which focus on the need for adequate staffing.